COMPASS WEALTH MANAGEMENT LLC

COMPASS WEALTH MANAGEMENT LLC 10 WATER ST. GUILFORD CT 06437 (203) 453-7000 CompassWealthManagement.com October 2025 This brochure provides information about the qualifications and business practices of Compass Wealth Management., LLC. If you have any questions about the contents of this brochure, please contact us at 203-453-7000. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities industry. Compass Wealth Management LLC is a Registered Investment Adviser. “Registration of” and “Investment Adviser” does not imply any level of skill or training. The oral and written communications of an Adviser provide you with the information about which you determine to hire or retain an Adviser. Additional information about Compass Wealth Management., LLC is also available on the SEC’s website at www.adviserinfo.sec.gov.  TABLE OF CONTENTS 1. COVER PAGE 2. TABLE OF CONTENTS 3. MATERIAL CHANGES 4. ADVISORY BUSINESS 5. FEES 6. PERFORMANCE BASED FEES 7. CLIENTS 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 9. DISCIPLINARY INFORMATION 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 11. CODE OF ETHICS 12. BROKERAGE PRACTICES, BEST EXECUTION AND SOFT DOLLARS 13. REVIEW OF ACCOUNTS 14. CLIENT REFERRALS AND OTHER COMPENSATION 15. CUSTODY 16. INVESTMENT DISCRETION 17. VOTING CLIENT SECURITIES 18. FINANCIAL INFORMATION  3. Material Changes Since the filing of our last annual updating amendment, dated February 6, 2025 we have the material changes to report. • Item 4 & 12: We have added language regarding our new recommendation of Charles Schwab as a qualified custodian of client assets. Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. We will further provide you with a new Brochure as necessary based on changes or new information at any time without charge. Currently, our Brochure may be requested by contacting our office at 203-453-7000. Additional information about Compass Wealth Management LLC is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with Compass Wealth Management LLC who are registered, or are required to be registered, as Investment Advisers of Compass Wealth Management LLC. 4. Advisory Business Compass Wealth Management. LLC was formed in February 1997 by William L. Matthes and Carolyn A. Matthes, and is currently owned by Jason Bear. Compass Wealth Management LLC is the name under which Jason Bear and his associates conduct business as Investment Advisers to individuals, corporations and pension plans. The investment advisory services provided by Compass Wealth Management LLC generally include: listed and over-the-counter securities, corporate, municipal and government bonds including agencies, mortgaged backed securities, certificates of deposit and exchange traded/index funds. An investment policy statement developed with the client’s participation determines the asset allocation of accounts and portfolio style. All clients are required to sign a written investment policy statement. The policy statement summarizes the client’s assets, goals and desired asset allocation. It then specifically describes the style of asset management to be used, prohibited transactions if any and criteria to be used in evaluating account performance. Compass Wealth Management LLC generally requires total assets of at least $50,000 to open a managed account. Mr. Bear is a Certified Financial Analyst, Portfolio Manager, and Investment Advisor. Mr. Radford Brogden, a Certified Financial Planner, joined the Firm in Q4 2020 and is an Investment Advisor Representative. Mr. Brogden assists with financial planning and other advisory services as directed. Emily Clare Cafasso joined the firm in Q3 2023 and is an Investment Advisor Representative. Ms. Cafasso assists with financial planning and other advisory services as directed. From time-to-time other investment advisors may be added of equally high caliber and strong credentials. As of December 31, 2024 , Compass Wealth Management’s accounts totaled $ 609,543,910 all in discretionary management. 5. Fees Advisory Services Compensation: Most clients pay a quarterly fee based on assets under management with all transaction costs being borne by the manager. We believe that this a preferred management style for most clients because it collapses all expenses into one, predictable fee. Compass Wealth Management bases its fees on a percentage of assets under management per annum and our fee schedule is below. Tier Rate First $999,999 1.00% 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  $1,000,000 - $4,999,999 0.80% $5,000,000 - $19,999,999 0.70% $20,000,000 - $49,999,999 0.60% $50mm+ 0.50% All fees are negotiable and there are no minimum fees. Fees are paid quarterly in advance. Initial fees may be prorated to cover the part of the quarter the account was under management. However, the prorated amount may be waived in the sole discretion of Compass Wealth Management. Thereafter the fee will be based on the account value at the last business day before the beginning of the new quarter. Upon termination of the account, management fees will be credited back to the client’s account based on the days remaining in the quarter. We also offer a flat fee advisory service in which the client pays an annual fee for investment/allocation advice. These are typically accounts with very low turnover and a large percentage of fixed income investments, that do not require the degree of portfolio management we provide other managed accounts. We are required to state that where the Investment Adviser absorbs the cost of all transactions it is possible that a conflict of interest could arise in which the Adviser may be hesitant to conduct trades that could be in the client’s best interest because of the cost of the trades to the adviser. However, this type of account is generally low turnover and trade cost to the advisor is minimal, and Compass does not hesitate to place trades for its clients. The transaction charge from the clearing firm is generally expressed as a single “ticket charge” plus exchange fees or handling cost. Clients utilizing Charles Schwab (Schwab) should be aware that Schwab has eliminated transaction fees for online trades of U.S. equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. This creates a conflict of interest as it incentives us to recommend Schwab as the custodian instead of Pershing (PAS) (described further in Item 12 below) since we do not pay transaction fees to Schwab in most cases. In the course of developing an investment portfolio for a client, Compass will invest the client’s money in a mutual fund or an ETF. These investment vehicles may carry separately incurred expenses, which we do not receive any part of, such as: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund's prospectus (i.e., fund management fees and other fund expenses). Financial Planning Compensation Description: We also offer standalone financial planning that has its own fee structure. Financial planning fees range from $0.00 to $10,000.00 and may be charged in addition to any fees charged for financial advisory services. In exchange for its receipt of the compensation as detailed above, Compass will provide the Client financial planning services. These services will include gathering personal financial information, either in person or via electronic means, and delivery of a financial plan consistent with Client’s financial goals and objectives. This plan will rely solely on information provided to Compass by the Client. Personal Financial Plan Depending on the Client’s situation and financial goals, the personal financial plan may include the following applicable analyses: Cash Flow Analysis: Compass will analyze Client’s current income and expenses and recommend specific courses of action to facilitate the funding of Client’s financial goals and objectives. Investment and Portfolio Analysis: Compass will evaluate Client’s investment goals, risk profile, current portfolio, and determine the potential of the current investment strategy to meet financial goals. Compass will prepare an asset allocation analysis and create a strategy consistent with Client’s risk tolerance and will coordinate the implementation of Client’s investment portfolio. 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  Executive Benefit Analysis: Compass will analyze 457(b) plans, collateral assignment split dollars, savings plans, stock options, retirement plans, payout alternatives, and payout timing choices and will coordinate employee benefits with Client’s overall asset allocation and financial goals. Retirement Income Analysis: Compass will determine, based upon currently available data and assumptions, the savings and investments necessary to achieve Client’s retirement income goals. Compass will also analyze the sensitivity of financial goals to inflation and expected rates of return and assist with coordination of Client’s savings plan, asset allocation, and investment strategy. Insurance Review: Compass will review Client’s insurance policies including life, disability, long-term care, homeowners, and auto and will provide recommendations to help ensure Client’s insurance program minimizes the financial risk to assets and indemnifies Client for insurable loses. Income Tax Review: Compass will review Client’s recent income tax returns, as well as current taxable income and expenses to incorporate projected tax liabilities into the personal financial plan. Compass can coordinate with Client’s CPA to provide information for tax planning purposes, as well as review the tax consequences of transactions or investments. Compass is not a tax advisor and does not provide specific tax advice. Estate Plan Review: Compass will coordinate with Client’s estate planning attorney to review Client’s current estate planning documents and help determine whether estate planning documents are consistent with Client’s current intentions. 6. Performance Based Fees Compass Wealth Management LLC does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of assets of a client). 7. Clients Compass Wealth Management LLC’s provides investment advice to many different types of clients. These clients generally include individuals, pension and profit-sharing plans, or charitable organizations. Compass Wealth Management LLC generally requires total assets of at least $50,000 to open a managed account. The minimum account size may be waived by Compass Wealth Management LLC in its sole discretion. 8. Methods of Analysis, Investment Strategies and Risk of Loss: Compass Wealth Management LLC generally relies on fundamental research which is available from corporate publications and annual reports, publications, newsletters, brokerage reports, electronic dissemination through Reuters, Bloomberg and Value Line. Investment strategies range from conservative to aggressive depending on the requirements of the client which are detailed in a written investment policy statement. These strategies are generally concentrated in listed equities and liquid fixed income securities, but may at times involve some small, illiquid stocks and lower quality, illiquid bonds if approved by the client in advance and judged to be suitable to the client’s risk tolerance and objectives. Investing in securities involves risk of loss that clients should be prepared to bear. Compass offers a flexible investment style of equity management to meet the needs of a wide range of clients. Generally, portfolios consist of large to medium capitalization companies, selling at reasonable valuations, diversified by industry group which Compass believes offers the opportunity for long term capital appreciation. In general, we prefer companies believed to be selling at a discount to their historic valuations. Fixed income accounts are managed for taxable and tax-free income. Compass generally diversifies fixed income accounts by maturity and avoids concentration in one maturity year which could lead to reinvestment risk or volatility from an excessively long maturity schedule. Municipal bonds of the state of residence of the client are used when appropriate for taxable accounts. Tax free accounts generally concentrate on corporate bonds which will be blended with government, agency and mortgaged backed securities as the relative yields present investment opportunities. Where appropriate, bonds of less than investment grade may be used as stipulated in the client’s investment policy statement. 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  Exchange Traded/Index Funds are recommended by the Adviser on a fee for service basis using a variety of investment styles. For aggressive investors willing to take on the added risk associated with sector funds. For less aggressive investors, the Adviser uses a balanced portfolio of funds selected on the basis of their long term past performance, diversified by investment sector, with periodic rebalancing. Risks Please note, investing in securities involves risk of loss that clients should be prepared to bear. There are different types of investments that involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy will be profitable or equal any specific performance level(s). Past performance is not indicative of future results. Our methods of analysis and investment strategies do not represent any significant or unusual risks, however all strategies have inherent risks and performance limitations such as: Market Risk - the risk that the value of securities may go up or down, sometimes rapidly or • unpredictably, due to factors affecting securities markets generally or particular industries. Interest Rate Risk - the risk that fixed income securities will decline in value because of an • increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. Credit Risk - the risk that an investor could lose money if the issuer or guarantor of a fixed • income security is unable or unwilling to meet its financial obligations. Mutual Funds - Investing in mutual funds carries the risk of capital loss and thus an investor • may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned below). Equity - investment generally refers to buying shares of stocks in return for receiving a future • payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. • Fixed Income - investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. • Exchange Traded Funds (ETFs) - An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  Non-U.S. Securities - present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Voting Client Securities -We do not have any authority to and do not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies; clients receive proxies directly from either custodians or transfer agents. Disciplinary Information 9. Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Compass Wealth Management LLC. Compass Wealth Management LLC has no legal or disciplinary events. Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each person providing investment advice. There are none. 10. Other Financial Industry Activities and Affiliations Compass Wealth Management LLC is a fully independent investment adviser solely operated by Jason Bear. Compass Wealth Management LLC and its representatives do not engage in any other financial industry activities or affiliations. 11. Code of Ethics Compass Wealth Management LLC has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, rumor mongering, restrictions of acceptance of significant gifts, and personal trading procedures, among other things. Compass Wealth Management LLC maintains a written “Code of Ethics” and will provide copies upon request. 12. Brokerage Practices, Best Execution and Soft Dollars All client funds and securities are held at PAS or Schwab (Qualified Custodians). Clients receive monthly statements from the Qualified Custodian. We encourage all clients to carefully review such statements and compare such official custodial records to the account statement we may provide you. Our statements may vary from custodial statements based on certain accounting procedures, reporting dates or valuation methodologies of certain securities. All trades will be directed to a registered broker-dealer deemed appropriate by the Advisor unless the client directs us otherwise. It is believed that this will be in the best interest of the clients because it allows the advisor to offer the lowest cost brokerage service available to the advisor, while offering a system of order execution and account management that is familiar to the advisor and uniform for all advisory clients. Accounts custodied at the Qualified Custodian will have the benefit of the best possible order execution available to the Investment Advisor at that time. Client Directed Brokerage While not routine, a client may direct us to use a broker-dealer to execute some or all transactions for the client. This brokerage direction must be requested by the client in writing. In that case, the client will negotiate terms and arrangements for the account with that broker-dealer, and we will not seek better execution services or prices from other broker- dealers or be able to “batch” client transactions for execution through other broker- dealers with orders for other accounts managed by us. By directing brokerage, the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Not all advisers require or allow their clients to direct 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  brokerage. Subject to our duty of best execution, we may decline a client’s request to direct brokerage if, in our sole discretion, such directed brokerage arrangements would result in additional operational difficulties. If the client requests us to arrange for the execution of securities brokerage transactions for the client’s account, we shall direct such transactions through broker-dealers that we reasonably believe will provide best execution. We shall periodically and systematically review our policies and procedures regarding recommending broker- dealers to our client in light of our duty to obtain best execution. Brokerage Selection Pershing We may recommend Pershing, LLC (Pershing), member of FINRA/SIPC (selected Broker/Dealer). Pershing is a widely recognized independent, and unaffiliated FINRA member broker-dealer. Pershing offers independent investment advisers program services which include custody of securities, trade execution, clearance and settlement of transactions. The primary factors considered in our decision to recommend Pershing include financial strength and the quality of the products and services offered to clients. Economic Benefits We receive support services from PAS and Pershing which assist us to better monitor and service program accounts maintained at Pershing. We receive some non-soft dollar benefits from Pershing. It is not the result of soft dollar arrangements or any other express arrangements with Pershing that involves the execution of client transactions as a condition to the receipt of services. These support services are provided to us based on the overall relationship between us and Pershing. These support services may include the following: investment-related research • pricing information and market data • software and other technology that provide access to client account data • compliance and/or practice management-related publications • consulting services • attendance at conferences, meetings, and other educational and/or social events • • marketing support computer hardware and/or software • • other products and services used by us in furtherance of our investment advisory business operations We will continue to receive the services regardless of the volume of client transactions executed with Pershing. Although the non-soft benefits will generally be used to service all our clients, a specific client may benefit more or less than another. As a result of receiving the services we may have an incentive to continue to use or expand the use of a particular custodian. We examined this potential conflict of interest when we chose to enter into the relationship with Pershing and we have determined that this relationship is in the best interest of our clients and satisfies our fiduciary obligations, including our duty to seek best execution. Some of the products and services made available by the selected Broker/Dealer may benefit us but may not benefit our client accounts. These products or services may assist us in managing and administering client accounts. Other services made available by the selected Broker/Dealer is intended to help us manage and further develop our business enterprise. 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  The benefits received by us or employees are not dependent on the amount of brokerage transactions directed to the selected Broker/Dealer. As part of our fiduciary duties to clients, we endeavor at all times to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by us or our employees in and of itself creates a potential conflict of interest and may indirectly influence our choice the selected Broker/Dealer for custody and brokerage services. As explained in Item 5, Clients pay a quarterly fee based on assets under management with all transaction costs being borne by the manager. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. While we will seek competitive rates, this is not applicable to Clients since transaction costs are not paid by the Client. Charles Schwab We generally recommend that our clients use Charles Schwab & Co., Inc. (Schwab), a registered broker dealer, member SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. We benefit from the products and services provided because the cost of these services would otherwise be borne directly by us, and this creates a conflict. You should consider these conflicts of interest when selecting a custodian. You should consider these conflicts of interest when selecting your custodian. We do not open the account for you, although we may assist you in doing so. How we select brokers/custodians We seek to recommend a custodian that will hold your assets and execute transactions. When considering whether the terms that Schwab provides are, overall, most advantageous to you when compared with other available providers and their services, we consider a wide range of factors, including: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc) and willingness to negotiate the prices • Reputation, financial strength, security, and stability • Prior service to us and our clients • Availability of other products and services that benefit us, as discussed below (see "Products and services available to us from Schwab") Your brokerage and trading costs For our clients' accounts that Schwab maintains, Schwab does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades may not incur Schwab commissions or transaction fees, however, these fees are 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  covered by Compass as explained above in Item 5. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab's Cash Features Program. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trade through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek "best execution" of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see "How we select brokers/ custodians"). Products and services available to us from Schwab Schwab Advisor ServicesTM is Schwab's business serving independent investment advisory firms like ours. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through our firm. Schwab also makes available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. Schwab's support services are generally available at no charge to us. Following is a more detailed description of Schwab's support services: Services that benefit you. Schwab's institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab'S services described in this paragraph generally benefit you and your account. Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both Schwab's own and that of third parties. We use this research to service all or a substantial number of our clients' accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, record keeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of a third party's fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab, we would be required to pay for these services from our own resources. Our interest in Schwab's services 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don't have to pay for Schwab's services and these services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our recommendation of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab's services (see "How we select brokers/custodians") and not Schwab's services that benefit only us. Trade Aggregation Trade aggregation is the act of trading a large block of a security in a single order. Shares of a purchased security are then allocated to the appropriate accounts in the appropriate proportion. The main purposes of order aggregation are (i) for ease of trading and (ii) to obtain a lower transaction cost associated with trading a larger quantity. We will sometimes place trades on a block trade basis, but will typically trade portfolio securities on an individual basis based on the client’s profile, needs and objectives. In a situation where we do not aggregate trades, clients purchasing securities around the same time may receive a less favorable price than other clients. Accounts for us or our employees may be included in a block trade with client accounts. 13. Review of Accounts All accounts are reviewed by Compass Wealth Management LLC at least quarterly. This review includes but is not limited to performance relative to an appropriate index, risk exposure relative to the client’s stated risk tolerance and investment objectives, and asset allocation relative to the client’s stated investment objectives. Most clients will receive monthly account statements of their positions and account balances. If there is no account activity in a given month, at minimum, clients will receive quarterly statements. Statements are prepared by an independent custodian; Pershing Adviser Solutions/Pershing LLC. Most clients receive quarterly, and on demand, performance reports which include: inception to date, quarterly and initiation to date performance relative to an appropriate index. Compass Wealth Management LLC provides quarterly reports which are prepared by its staff using third party software. Generally, the reports are not audited by a third party and are intended as an informational supplement to the client’s monthly, independently prepared account statement from the custodian. Compass will arrange for a third-party audit of the performance reports and separately bill the client at cost for this service upon request. Compass will also provide the raw data necessary for the client’s agent to perform an independent audit at no charge to the client. All clients are encouraged to personally contact their advisor as often as they would like to. Other reports are available from software resources which may be helpful to the client and the advisor in understanding the client’s asset positioning. The scope of additional reporting will vary depending on the client’s requests, complexity of the account and any restrictions placed on the account. 14. Client Referrals and Other Compensation Compass Wealth Management LLC does not directly or indirectly compensate any person for client referrals. 15. Custody Custody means holding, directly or indirectly, client funds or securities or having any authority to obtain possession of them. Compass Wealth Management LLC does not have direct custody of any client funds and/or securities. Compass Wealth Management LLC will not maintain physical possession of client funds and securities. Instead, clients’ funds and securities are held by a qualified custodian. 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  While Compass Wealth Management LLC does not have physical custody of client funds or securities, payments of fees may be paid by the custodian from the custodial brokerage account that holds client funds pursuant to the client’s account application. In certain jurisdictions, the ability of Compass Wealth Management LLC to withdraw its management fees from the client’s account may be deemed custody. Prior to permitting direct debit of fees, each client provides written authorization permitting fees to be paid directly from the custodian. As part of the billing process, the client’s custodian is advised of the amount of the fee to be deducted from that client’s account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. The custodian does not calculate the amount of the fee to be deducted and does not verify the accuracy of Compass Wealth Management LLC’s advisory calculation. Therefore, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation. Clients should contact Compass Wealth Management LLC directly if they believe that there may be an error in their statement. The current custodian Compass currently utilizes is Pershing Advisor Solutions (PAS). 16. Investment Discretion Compass Wealth Management LLC receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. However, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining amounts, Compass Wealth Management LLC observes the investment policies, limitations and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to Compass Wealth Management LLC in writing. 17. Voting Client Securities As a matter of firm policy and practice, Compass Wealth Management LLC does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Compass Wealth Management LLC may provide advice to clients regarding the clients’ voting of proxies. 18. Financial Information The Firm has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com 

COMPASS WEALTH MANAGEMENT LLC 10 WATER ST. GUILFORD CT 06437 (203) 453-7000 CompassWealthManagement.com Part 2A Appendix 1 of Form ADV Wrap Fee Program Brochure October 2025 This wrap fee brochure provides information about the qualifications and business practices of Compass Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at 203-453-7000. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities industry. Compass Wealth Management LLC is a Registered Investment Adviser. “Registration of” and “Investment Adviser” does not imply any level of skill or training. The oral and written communications of an Adviser provide you with the information about which you determine to hire or retain an Adviser. Additional information about Compass Wealth Management., LLC is also available on the SEC’s website at www.adviserinfo.sec.gov.  TABLE OF CONTENTS 1. COVER PAGE 2. TABLE OF CONTENTS 3. MATERIAL CHANGES 4. SERVICES, FEES AND COMPENSATION 5. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS 6. PORTFOLIO MANAGER SELECTION AND EVALUATION 7. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS 8. CLIENT CONTACT WITH PORTFOLIO MANAGERS 9. ADDITIONAL INFORMATION  3. Material Changes Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. Since our last update on February 6, 2025, we have the material changes to report. • We have added language regarding our new recommendation of Charles Schwab as a qualified custodian of client assets. We will further provide you with a new Brochure as necessary based on changes or new information at any time without charge. Currently, our Brochure may be requested by contacting our office at 203-453-7000. Additional information about Compass Wealth Management, LLC is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with Compass Wealth Management, LLC who are registered, or are required to be registered, as Investment Advisers of Compass Wealth Management, LLC. 4. Services, Fees and Compensation Services We are both the sponsor and investment manager of the Compass Wrap Fee Program (the Program). A “wrap- fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client is not charged separate fees by Compass for the respective components of the total service. Compass Wealth Management (Compass, we, our, us) offers asset management services based on the individual needs of the client. This Brochure provides a description of the advisory services offered under the Compass Wrap program. For more information about Advisor’s other investment advisory services, please contact us for a copy of a similar brochure that describes such services or go to www.adviserinfo.sec.gov. In the Compass Wrap program, we provide ongoing investment advice and management on assets in the client’s account. We provide advice on the purchase and sale of various types of investments, such as listed and over- the-counter securities, corporate, municipal and government bonds including agencies, mortgaged backed securities, certificates of deposit and exchange traded/index funds. We provide advice that is tailored to the individual needs of the client based on the investment objective chosen by the client. Clients may request restrictions on investing in certain securities or groups of securities. Compass will make a reasonable effort to honor those restrictions and if we are unable to, we will notify the client before taking action. We provide management services on a discretionary basis. The client authorizes Compass to have discretion by signing a Discretionary Asset Management Agreement. Assets for program accounts are often held in a custodial account at Pershing Advisory Solutions (PAS), Charles Schwab (“Schwab”), or another third-party custodian. PAS and Schwab act as the executing broker/dealer for transactions placed in PAS and Schwab custodial accounts, and provides other administrative services as described throughout this Brochure. Fees In the Compass Wrap Program, clients pay us a single annual advisory fee for advisory services and execution of transactions. Clients do not pay brokerage commissions or transaction charges for execution of transactions in addition to the advisory fee; however, dealer markups or other embedded costs may still apply. The advisory fee is negotiable between the client and the Advisor and is set out in the advisory agreement. The advisory fee is a percentage based on the value of all assets in the account, including cash holdings. The advisory fee is paid to Compass and is shared between Compass and its associated persons. We do not accept performance-based fees for program accounts. Our fee schedule is described below: 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  Tier Rate First $999,999 1.00% $1,000,000 - $4,999,999 0.80% $5,000,000 - $19,999,999 0.70% $20,000,000 - $49,999,999 0.60% $50mm+ 0.50% The advisory fee is deducted from the account by the custodian of the assets based on a written authorization from the client or by a bill sent directly to the client. The quarterly advisory fee is calculated by Compass and transmitted to the custodian. If the advisory agreement is terminated before the end of the quarterly period, client is entitled to a pro-rated refund of any pre-paid quarterly advisory fee based on the number of days remaining in the quarter after the termination date. Although clients do not pay a transaction charge for transactions in a program account, clients should be aware that Compass pays the custodian transaction charges for the transactions. The transaction charges paid by us vary based on the type of transaction (e.g., mutual fund, equity or fixed income security) and range from $0 to $25. Because we pay the transaction charges in program accounts, there is a conflict of interest. Clients should understand that the cost to us for transaction charges may be a factor that we consider when deciding which securities to select and how frequently to place transactions in a program account. Clients utilizing Schwab should be aware that Schwab has eliminated transaction fees for online trades of U.S. equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. This creates a conflict of interest as it incentives us to recommend Schwab as the custodian instead of PAS since we do not pay transaction fees to Schwab in most cases. Other Types of Fees and Charges Program accounts will incur additional fees and charges from parties other than us as noted below. These fees and charges are in addition to the advisory fee paid to us. We do not share in any portion of these third-party fees. For example, PAS may serve as the custodian and the broker-dealer providing brokerage and execution services on program accounts and consequently impose certain fees and charges. Clients are notified of such charges at account opening and a list of these fees and charges are generally posted on the custodian’s website. The custodian will commonly deduct these fees and charges directly from the client’s program account. There are other fees and charges that are imposed by other third parties that apply to investments in program accounts. Some of these fees and charges are described below. If a client’s assets are invested in mutual funds or other pooled investment products, clients • should be aware that there will be two layers of advisory fees and expenses for those assets. Client will pay an advisory fee to the fund manager and other expenses as a shareholder of the fund. This is known as the Expense Ratio. Client will also pay us the advisory fee with respect to those assets. Some of the mutual funds available in the program may be purchased directly. Therefore, clients could generally avoid the second layer of fees by not using our management services and by making their own investment decisions. We consider the impact of fees when making investment allocations and seek to keep fees at a minimum. Certain mutual funds impose fees and charges such as contingent deferred sales charges, early • redemption fees and charges for frequent trading. These charges may apply if client transfers into or purchases such a fund with the applicable charges in a program account. 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  Although only no-load and load-waived mutual funds can be purchased in a program account, • client should understand that some mutual funds pay asset based sales charges or service fees (e.g., 12b- 1 fees) to the custodian with respect to account holdings. Further information regarding fees assessed by a mutual fund, ETF or other investment vehicle is available in the appropriate prospectus, which is available upon request from us or from the product sponsor directly. Our wrap fee covers our advisory services and most brokerage services provided by Schwab including custody of assets, equity trades, ETFs, and agency transactions in fixed income securities. As a result, we have an incentive to execute transactions for your account at Schwab. Our wrap fee does not cover all fees and costs. The fees not included in the wrap fee include charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees (such as a commission or markup) for trades executed away from Schwab at another broker-dealer, margin interest, wire transfer fees and other cashiering fees and taxes on brokerage accounts and securities transactions. Other Important Considerations The advisory fee is an ongoing wrap fee for investment advisory services, the execution of • transactions and other administrative and custodial services. The advisory fee may cost the client more than purchasing the program services separately, for example, paying an advisory fee plus commissions for each transaction in the account. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the type and size of the account, historical and or expected size or number of trades for the account, and number and range of supplementary advisory and client-related services provided to the client. • The advisory fee also may cost the client more than if assets were held in a traditional brokerage account. In a brokerage account, a client is charged a commission for each transaction, and the representative has no duty to provide ongoing advice with respect to the account. If the client plans to follow a buy and hold strategy for the account or does not wish to purchase ongoing investment advice or management services, the client should consider opening a brokerage account rather than a program account. We recommend the program to the client, and Compass receives compensation as a result of • the client’s participation in the program. This compensation includes the advisory fee and also may include other compensation, such as bonuses, awards or other things of value offered by the custodian to us or our associated persons. The amount of this compensation may be more or less than what Compass would receive if the client participated in other wrap fee programs, programs of other investment advisors or paid separately for investment advice, brokerage and other client services. Therefore, we may have a financial incentive to recommend a particular program account over other programs and services. The investment products available to be purchased in the program can be purchased by clients • outside of a program account, through broker-dealers or other investment firms not affiliated with Compass. 5. Account Requirements and Types of Clients Compass Wealth Management LLC generally requires total assets of at least $50,000 to open a managed account. Waivers or exceptions to the minimum account requirement may be granted at the discretion of Compass. 6. Portfolio Management Selection and Evaluation 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  In the Compass Wrap program, we do not select, review or recommend other investment advisors or portfolio managers. Through our associated persons, we are responsible for the investment advice and management offered to clients. We generally require that individuals involved in determining or giving investment advice have several years of experience dealing with individuals and small business. In our Wrap program, we provide ongoing investment advice and management on assets in the client’s account. We provide advice on the purchase and sale of various types of investments, such as mutual funds, exchange- traded funds (“ETFs”), equities, fixed income securities. We provide advice that is tailored to the individual needs of the client based on the investment objective chosen by the client. Clients may request restrictions on investing in certain securities or groups of securities by indicating in the written advisory agreement with us. Methods of Analysis Compass Wealth Management LLC generally relies on fundamental research which is available from corporate publications and annual reports, publications, newsletters, brokerage reports, electronic dissemination through Reuters, Bloomberg and Value Line. Investment strategies range from conservative to aggressive depending on the requirements of the client which are detailed in a written investment policy statement. These strategies are generally concentrated in listed equities and liquid fixed income securities, but may at times involve some small, illiquid stocks and lower quality, illiquid bonds if approved by the client in advance and judged to be suitable to the client’s risk tolerance and objectives. Investing in securities involves risk of loss that clients should be prepared to bear. Compass offers a flexible investment style of equity management to meet the needs of a wide range of clients. Generally, portfolios consist of large to medium capitalization companies, selling at reasonable valuations, diversified by industry group which Compass believes offers the opportunity for long term capital appreciation. In general, we prefer companies believed to be selling at a discount to their historic valuations. Fixed income accounts are managed for taxable and tax-free income. Compass generally diversifies fixed income accounts by maturity and avoids concentration in one maturity year which could lead to reinvestment risk or volatility from an excessively long maturity schedule. Municipal bonds of the state of residence of the client are used when appropriate for taxable accounts. Tax free accounts generally concentrate on corporate bonds which will be blended with government, agency and mortgaged backed securities as the relative yields present investment opportunities. Where appropriate, bonds of less than investment grade may be used as stipulated in the client’s investment policy statement. Exchange Traded/Index Funds are recommended by the Adviser on a fee for service basis using a variety of investment styles. For aggressive investors willing to take on the added risk associated with sector funds. For less aggressive investors, the Adviser uses a balanced portfolio of funds selected on the basis of their long term past performance, diversified by investment sector, with periodic rebalancing. Risks Please note, investing in securities involves risk of loss that clients should be prepared to bear. There are different types of investments that involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy will be profitable or equal any specific performance level(s). Past performance is not indicative of future results. Our methods of analysis and investment strategies do not represent any significant or unusual risks, however all strategies have inherent risks and performance limitations such as: Market Risk - the risk that the value of securities may go up or down, sometimes rapidly or • unpredictably, due to factors affecting securities markets generally or particular industries. 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  Interest Rate Risk - the risk that fixed income securities will decline in value because of an • increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. Credit Risk - the risk that an investor could lose money if the issuer or guarantor of a fixed • income security is unable or unwilling to meet its financial obligations. Mutual Funds - Investing in mutual funds carries the risk of capital loss and thus an investor • may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned below). Equity - investment generally refers to buying shares of stocks in return for receiving a future • payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. • Fixed Income - investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. • Exchange Traded Funds (ETFs) - An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Non-U.S. Securities - present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Voting Client Securities -We do not have any authority to and do not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies; clients receive proxies directly from either custodians or transfer agents. 7. Client Information Provided to Portfolio Managers In the Compass Wrap program, we are responsible for account management; there is no separate portfolio manager involved. We obtain the necessary financial data from the client and assist the client in setting an appropriate investment objective for the account. We obtain this information by having the client complete an advisory agreement and other documentation. Clients are encouraged to contact us if there have been any changes in the client’s financial situation or investment objectives or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Client should be aware that the investment objective selected for the program is an overall objective for the entire account and may be 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  inconsistent with a particular holding and the account’s performance at any time. Client should further be aware that achievement of the stated investment objective is a long-term goal for the account. The Firm policy requires an annual client meeting (one review every 12 months) to determine if there have been any changes in the client's financial situation, investment objectives, or restrictions. In addition, the meeting should incorporate the account performance, appropriateness of the account, and any other information determined pertinent to the client situation. The annual meeting may occur by phone, in person, via e-mail, or via video conference and documentation will be maintained to evidence that at a minimum the following topics were reviewed: The client’s financial status • Risk Tolerance • Time Horizon • Investment Objective and Goals • Asset Allocation and/or Account Holdings • Additionally, on a quarterly basis, IARs should review the performance of the client's advisory account and investment objectives. 8. Client Contact with Portfolio Managers There are no restrictions on a client’s ability to contact and consult with us. We encourage clients to contact us with any questions they may have regarding the management of their account. 9. Additional Information A. Disciplinary Information: Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Compass Wealth Management, LLC. Compass Wealth Management LLC has no legal or disciplinary even. B. Other Financial Industry Activities and Affiliations Compass Wealth Management LLC is a fully independent investment adviser operated by Jason Bear. C. Code of Ethics Compass Wealth Management, LLC has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, rumor mongering, restrictions of acceptance of significant gifts, and personal trading procedures, among other things. Compass Wealth Management LLC maintains a written “Code of Ethics” and will provide copies upon request. D. Review of Accounts All accounts are reviewed by Compass Wealth Management, LLC at least quarterly. This review includes, but is not limited to performance relative to an appropriate index, risk exposure relative to the client’s stated risk tolerance and investment objectives, and asset allocation relative to the client’s stated investment objectives. Most clients will receive monthly account statements of their positions and account balances. If there is no account activity in a given month, at minimum, clients will receive quarterly statements. Statements are prepared by an independent custodian; Pershing Adviser Services/Pershing LLC and Charles Schwab/Schwab Advisory 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com  Services. Most clients receive quarterly, and on demand, performance reports which include: inception to date, quarterly and initiation to date performance relative to an appropriate index. Compass Wealth Management LLC provides quarterly reports which are prepared by its staff using third party software. Generally, the reports are not audited by a third party and are intended as an informational supplement to the client’s monthly, independently prepared account statement from the custodian. Compass will arrange for a third party audit of the performance reports and separately bill the client at cost for this service. Compass will also provide the raw data necessary for the client’s agent to perform an independent audit at no charge to the client. All clients are encouraged to personally contact their advisor as often as they would like to. Other reports are available from software resources which may be helpful to the client and the advisor in understanding the client’s asset positioning. The scope of additional reporting will vary depending on the client’s requests, complexity of the account and any restrictions placed on the account. E. Client Referrals and Other Compensation Compass Wealth Management LLC does not directly or indirectly compensate any person for client referrals. 10 Water Street, Guilford CT 06437 | 203.453.7000 | www.CompassWealthManagement.com